ACA Reporting: - PowerPoint Presentation

Slide1

ACA Reporting:Preparing for 2016 Deadlines

Bradley Arends

Alliance Benefit Group Financial Services, Corp.

Stacey Rice

Cargill, Incorporated

Liz Deckman

Holly Fistler

Melinda Maher

Bob Seng

Dorsey & Whitney

LLP

July 13, 2015Slide2

Add Dorsey ERISA blog link

Tweet this event at

#dorseyACAFollow us on Twitter using: @dorseyERISASlide3

A few updates

NEWS FLASH: More ACA rules delayed …!!!!

King v. BurwellBlack/Thompson (HR 2712)Warner/PortmanSlide4

Pieces of ACA especially relevant for today

Employer Shared Responsibility Provisions (Employer Mandate)

Individual Shared Responsibility (Individual Mandate)Subsidies / Premium Tax CreditSlide5

Agenda for TodayAdministration & Workflow for ACA reporting

1094-C

Controlled groups, Applicable Large Employers, ALE Members, Aggregated ALE GroupsAuthoritative TransmittalsLine 22 1095-CLine 14Line 15Line 16Slide6

Administration & WorkflowPayroll vendor or system

HRIS

COBRA administratorHealth Plan TPAACA reporting vendorBuild a grid?BAAs?Slide7

1094-C – Cover Sheet

The 1094-C demonstrates compliance with the Employer Mandate

The 1094-C serves as a Transmittal form for individual Forms 1095-C when they go to the IRSThe 1094-C contains Controlled Group / Aggregated Large Employer Group information for the IRSSlide8

Foreshadowing – 1095-C

The 1095-C is a little like a Form W-2

An employer subject to ACA will issue several Forms 1095-C to certain individualsThe employer also files the Forms 1095-C with the IRS, using the 1094-C as a cover pageIndividual demonstrates compliance with Individual Mandate to IRSInformation to IRS on offers of coverage that may affect subsidy eligibilitySlide9

Compare & ContrastSlide10

1094-C – Find Your Controlled Group

“Controlled group” is an IRS term used to describe companies under common control.Slide11

1094-C – Controlled Groups

Controlled Groups come in a few flavors

Parent – SubsidiaryBrother – SisterAffiliated ServiceCombinations of theseSlide12

1094-C – Controlled Group Tips

Talk to your tax people

Look at your IRS determination letter filings for qualified retirement plansSlide13

1094-C – Controlled Group Tips

Individuals, trusts, partnerships that own groups of companies (brother-sister)

Churches or government institutions with various operations (good faith interpretation)Groups of companies that or partnerships that provide services to each other (affiliated service groups)Slide14

1094-C – Controlled Groups to Aggregated ALE Groups

Any controlled group with an average of 50 or more FTEs on business days in 2014 is an

“Aggregated ALE Group” for 2015Slide15

1094-C – What it Means to be an Aggregated ALE Group

Aggregated ALE Groups

are subject to the Employer Mandate in 2015Aggregated ALE Groups are subject to ACA reporting for 2015 calendar yearSee 1094/1095-C instructions at page 9 for a definition of “Aggregated ALE Group”Slide16

1094-C – Aggregated ALE Group

This is an Aggregated ALE GroupSlide17

Aside – It’s 2015. Where are your Employees

We are looking for common law employees

LeasedSeasonalEtc.Slide18

1094-C – ALE Member

An “

ALE Member” is a Member of an Aggregated ALE Group that:Has its own EINHas 1 or more employeesSlide19

1094-C – ALE Member Responsibilities

Each

“ALE Member” is responsible for filing a Form 1094-C.Some “ALE Members” may file multiple Forms 1094-C, but one of those forms should be the “Authoritative Transmittal.”Slide20

1094-C – Aggregated ALE Group

Find the ALE MembersSlide21

1094-C Aggregated ALE GroupSlide22

1094-C – Applied LearningSlide23

1094-C, Part I

EINSlide24

1094-C, Part II, Lines 19-21

s

ame as controlled group

Part IV is a list of controlled group members

Each ALE Member files 1 “authoritative transmittal”Slide25

1094-C, Part II, Line 22Slide26

1094-C, Part IIISlide27

1094-C, Part IV

This is a list of “ALE Members,” aka, your controlled group.Slide28

Cleanse the Palate(healthyeating.sfgate.com)

Crackers

Lemon sorbetPickled gingerMilkSlide29

And Start Thinking About Form 1095-C

Like a W-2

Shows whether offer of coverage has been made Employer MandateSubsidiesFiled with the IRSDistributed to EmployeesSlide30

1095-C / Some Terms & RulesRules for identifying full-time employees

Monthly measurement period

Look-back measurement periodInitial measurement periodStandard measurement periodStability periodLimited Non-Assessment PeriodMultiemployer interim rule reliefQualifying OfferSlide31

Examples – Form 1095-C, Lines 14-16

Ongoing full-time employee

Employee and spouse enrolled in minimum value self-insured plan all year; child added in July

Self-only, minimum value coverage is $110/monthSlide32

Examples – Form 1095-C, Lines 14-16

Newly hired full-time employee

Employee hired March 15

th

Waiting period: employees eligible on 1

st

of month after 60 days of employment

“Qualifying Offer” made on June 1

st

Not offered coverage

Offered coverage

Not yet an employee

Waiting period

Enrolled in coverageSlide33

Examples – Form 1095-C, Lines 14-16

Newly hired variable hour employee

Employee hired March 15

th

with variable schedule

Initial measurement period March 15, 2015 through March 14, 2016

No Form 1095-C for 2015 – not (yet) a full-time employee

[No Form 1095-C for 2015]Slide34

Examples – Form 1095-C, Lines 14-16

Newly hired variable hour employee (cont’d)

Employee averages 32 hours/week

No waiting period; employee is eligible first of month following end of initial measurement period

Form 1095-C for 2016:

Not offered coverage

Offered coverage

Initial measurement period

Enrolled in coverageSlide35

Examples – Form 1095-C, Lines 14-16

Terminated employee

Employee waived coverage at open enrollment

Self-only, minimum value coverage is $110/month

Employer set employee contributions using W-2 safe harbor

Employment terminated on August 15

th

; plan offers coverage through date of termination

Offered coverage

Not offered coverage

Offer satisfies safe harbor

Employed part of Aug.; then not an employee Slide36

Examples – Form 1095-C, Lines 14-16

Terminating employee elects COBRA coverage

Employee, family enrolled in minimum value coverage Self-only, minimum value coverage is $110/monthEmployment terminated on July 20th; plan offers coverage through date of terminationCOBRA offered and accepted for family; $300/month for single coverage

Offered coverage

Employee premium

COBRA premiumSlide37

Examples – Form 1095-C, Lines 14-16

Reduction in hours (Monthly Measurement)

Employee, family enrolled in minimum value coverage

Self-only, minimum value coverage is $110/month

Employee goes to part-time hours in August; coverage terminates end of July

COBRA offered waived; $300/month for single coverage

Enrolled in coverage

Not enrolled; part time employee

Offered coverageSlide38

Examples – Form 1095-C, Lines 14-16

Reduction in hours (Look Back Measurement)

Variable hour employee, family enrolled in minimum value coverage

Self-only, minimum value coverage is $110/month

Employee goes to part-time hours in August; coverage continues through end of stability period

Enrolled in coverage

Offered coverageSlide39

Examples – Form 1095-C, Lines 14-16

COBRA coverage for non-employee

Employee and spouse enrolled in minimum value coverage; divorce on May 15

th

For January through May, spouse reported on employee’s Form 1095-CSlide40

Examples – Form 1095-C, Lines 14-16

For June through December, former spouse receives

separate Form 1095-CSlide41

Form 1095-C, Part III

Do I really need SSNs?

Rules for checking boxesSlide42

Questions

Elizabeth Deckman

Dorsey & Whitney │SeattlePartner(206) 903-2419deckman.liz@dorsey.comA. Melinda Maher Dorsey & Whitney │MinneapolisPartner(612) 492-6082maher.melinda@dorsey.com

Bob Seng

Dorsey & Whitney │Minneapolis

Partner

(612) 492-6071

seng.bob@dorsey.com

Holly A. Fistler

Dorsey & Whitney │Minneapolis

Associate

(612) 492-6072

fistler.holly@dorsey.com

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